BRIEFLY

Churchill Downs declined to act on an offer.

Thomas H. Meeker, president and chief executive of Churchill Downs Inc., said the track's board was advised by counsel that the buy-out offer by wealthy investor Louis E. Wolfson doesn't constitute a formal offer that the board can evaluate. Earlier this month, Wolfson offered Churchill Downs shareholders $120 a share in cash for their holdings. Total value of the offer is more than $46 million.